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WALTER v. COMMISSIONER

Dkt. No. 8321-05.

93 T.C.M. 644 (2007)

T.C. Memo. 2007-2

Edward L. Walter and Jamie K. Walter v. Commissioner.

United States Tax Court.

January 3, 2007.

Attorney(s) appearing for the Case

Deborah R. Jaffe and Robert M. McCallum, for petitioners.

Julie L. Payne, for respondent.

MEMORANDUM OPINION

LARO, Judge:

This case is before the Court for decision without trial. See Rule 122.1 Petitioners petitioned the Court to redetermine respondent's determination of a $167,401 deficiency in their 2000 Federal income tax and an addition to tax of $5,197.70 under section 6651(a). After concessions by respondent, we are left to decide the date on which to value stock transferred to Edward Walter (petitioner) through...

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